I am reading things that give me some different ways to look at when a part time employee has to be offered health insurance so I need some clarification. We employee over 100 employees of which 40 to 50 are full time. I have two part time employees who have averaged 33+ hours over the last three months. Do we have to offer them health insurance at this time or can you average the employees hours over a quarter?


Under the ACA employers can use look-back periods of between 3 and 12 months. If an employee works more than 30 hours a week over a 120 day period, or at least 130 hours a month, they are considered full-time. An employer can count actual hours worked, days-worked equivalency, or weeks-worked equivalency. The fee for not getting it right is a per-month, per-employee fee.

The above applies to determining full-time status for the fee. The calculation for the requirement to provide coverage is simpler and revolves around counting full-time equivalent employees (and reasonable accreditation of employee hours).

Learn more about the employer mandate here.

For further details see IRS QA on look-back periods under the ACA and IRS reasonable methods for crediting hours.

Rate and Comment on the Answer

Your email address will not be published. Required fields are marked *

1 2 3 4 5

This site uses Akismet to reduce spam. Learn how your comment data is processed.

Susan on

Answer Rating:

Question – I am the director of a preschool program. I have 16 teachers who teach 3, 4 and 5 year olds. The teachers teach about 8 months of the year – from September to mid May with two weeks off at Christmas, a week off for Spring Break, etc.

Most of my teachers work very part time – T/Th mornings, M/W/F mornings. I have two classes that have a session in the morning and a session in the afternoon. Therefore,two or three teachers end up working between 30 and 40 hours a week.

My question is…. do I take how many hours all of the teachers are all working…. over a 9 month period (really 8 months) and divide to come up with an average … to see if this is acceptable.

I would so appreciate any feedback! Thank you!

ObamaCareFacts.com on

Answer Rating:

The employer can choose a look-back period to determine if they have to offer coverage under the mandate. Adjunct teacher hours are counted a little differently. IRS issued detailed guidance (which can be found in the links above), but is explained simply here: https://www.insidehighered.com/news/2014/02/11/irs-guidance-health-care-law-clarifies-formula-counting-adjunct-hours

If you do have to offer coverage then you’ll need to look at if a teacher is full-time while they are working. If they are working an average of 30 hours a week, and you have to comply with the mandate, then you offer coverage. I don’t believe the off season (during the summer) would affect their being full or part-time during the year.

So like you say for the purposes of offering coverage look at that 8 month period where everyone is working and then for determining full-time status it is based on what is happening now. For instance if a teacher was full-time, but is now part-time (they are currently working 10 hours a week and will be) they don’t need to be offered coverage… but you do want to count those hours toward your total full-time equivalent hours for the purposes of the mandate.

That is the gist of things, we do suggest taking a closer look at IRS guidelines for more details: http://www.irs.gov/Affordable-Care-Act/Employers/Questions-and-Answers-on-Employer-Shared-Responsibility-Provisions-Under-the-Affordable-Care-Act